This revenue procedure describes a program that provides an opportunity for fast-track processing of certain requests for letter rulings solely or primarily under the jurisdiction of the Associate Chief Counsel (Corporate). This new program replaces the pilot program established by Rev. Proc. 2022-10, 2022-6 I.R.B. 473.

26 CFR 601.201: Rulings and determination letters.

These proposed rules would amend the definition of short-term, limited-duration insurance for purposes of the exclusion from the definition of “individual health insurance coverage” in 26 CFR part 54, 29 CFR part 2590, and 45 CFR part 144. These proposed rules would also amend the requirements for hospital indemnity and other fixed indemnity insurance to be treated as an excepted benefit in the group and individual health insurance markets. In addition, Treasury and IRS propose rules that would clarify the tax treatment of amounts received by a taxpayer through certain employment-based accident or health insurance that generally are paid without regard to incurred medical expenses in 26 CFR part 1. If finalized, the proposed rule would include in income and wages benefits from fixed indemnity policies purchased with employer funds, including by salary reduction through a section 125 cafeteria plan. Furthermore, these proposed rules include technical amendments to clarify that, under longstanding regulations and guidance, the substantiation requirements for reimbursement of qualified medical care expenses apply to reimbursements under section 105(b) of the Internal Revenue Code in order for those reimbursements to be excluded from an individual’s gross income.

This revenue ruling provides that if a taxpayer stakes cryptocurrency native to a proof-of-stake blockchain and receives additional units of cryptocurrency as rewards when validation occurs, the fair market value of the rewards received is included in the taxpayer’s gross income in the taxable year in which the taxpayer gains dominion and control over the rewards. The fair market value is determined as of the date and time the taxpayer gains dominion and control over the rewards. The revenue ruling also clarifies that this also is the case if a taxpayer stakes cryptocurrency through a cryptocurrency exchange and the taxpayer receives additional units of cryptocurrency as rewards as a result of the validation.

26 CFR 1.61-1: Gross income.

(Also § 61)